Consultation on reducing fluorinated greenhouse gas emissions - Further action at EU level

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1 Consultation on reducing fluorinated greenhouse gas emissions - Further action at EU level Meta Informations Creation date Last update date User name null Case Number Invitation Ref. Status N Language en General information about you Please, enter your name and, where relevant, the name of the organisation you represent. Please include also address for contact purposes for use only if we need clarification about your response. Petri Hannula, Suomen Kylmäyhdistys ry; petri.hannula@skll.fi I am replying as / on behalf of: organised stakeholders Please enter your registration number in the Transparency Register. It is Commission policy to treat submissions from organisations that choose not to register as individual contributions (see exceptions). Please check the validity of your entry via the search function in the Transparency register invalid entries will by default be regarded as unregistered Please specify the category that most closely describe your organization Please indicate your country or, where relevant, the geographical area you represent other type of companies/ professional association Finland

2 Please select the option best describing the use category relevant for you, if any (max 3 choices) commercial refrigeration and freezing industrial refrigeration and freezing heat pumps We may publish your response, under the name indicated - I consent together with your identity, on the to publication of all information in my Commission website, where it will be contribution and declare that none of publicly accessible. Though if you it is under copyright restrictions that request it, publication will be prevent publication. anonymous. How would you prefer your contribution to be published, if at all? Questions on choice of policy action The European Commission is looking to set out a plan to reduce EU emissions by 80-95% by In this context, how do you judge current EU policies on greenhouse gas emissions from F- gases (e.g. the F-Gas Regulation on certain F-gases and the Directive on mobile air-conditioning)? no opinion What are the main obstacles to switching to alternative technologies with lower impact on the climate (i.e. fluids with low global warming potentials or other non-in-kind technologies) in the applications currently relying upon F-gases? (max 3 choices) In the absence of global action to phase-down HFCs, which options would you consider the most appropriate, at EU level, to contribute to the established targets for reducing greenhouse gas emissions? (max. 3 choices) alternative technologies will require higher initial investments alternative technologies will not meet the same performance standards (e.g. reliability, energy efficiency, insulation properties etc) alternative technologies will require greater effort to meet the same safety standards encouraging voluntary agreements for specific sectors where replacement is technically feasible and cost-effective strengthening, where possible, measures aiming at containment and proper recovery of F-gases (e.g. through stricter and/or broader application of existing measures in the F-gas Regulation) If a global agreement to phase-down HFCs is eventually concluded, which policy options (if any) would be the encouraging voluntary agreements for specific sectors where replacement is technically feasible and cost-effective

3 most appropriate to complement, at EU level, the establishment of maximum, gradually declining, limits for the quantity of HFCs placed on the EU market expressed in terms of CO2 equivalent. (max 3 choices) strengthening, where possible, measures aiming at containment and proper recovery of F-gases (e.g. through stricter and/or broader application of existing rules in the F- gas Regulation) If you have a specific suggestion on how to reduce leaks and improve recovery of F-gases from products through stricter and/or broader application of the type of measures already present in the F-gas Regulation, please briefly specify below: The F-gas Regulation firstly needs to be fully implemented and enforced throughout the EU. An effective control system in every member country is a must. Central (national) registration of all RACHP systems containing fluorinated gases is a base of this. This registration might also be an effective way to handle voluntary agreements. Best practises from different member countries should take to wider use. A good example of good practises is the registration system in Slovakia. Stipulate mandatory registration of certified companies and personnel in order to facilitate controls, compliance and mutual recognition between Member States. Ensure all RACHP systems are only installed and commissioned by properly qualified technicians by restricting sales of refrigerants and pre-charged split systems only to registered professionals. Reducing the 3 kgs threshold to 0,5 kg on control and leak testing. Include mobile refrigeration (maritime, road, rail) in the Regulation s scope. If you have any specific suggestions of technical adjustments to the current F-gas Regulation, e.g. to clarify its provisions, please briefly specify below: Article 5, paragraph 4 of the F-Gas Regulation should be amended in order to switch the responsibility of selling fluorinated gases in containers to certified installers on wholesalers/distributors. To the same paragraph it s then easy to include precharged non-monobloc systems (mini-splits etc.), which also includes refrigerants like containers. In EU level thousands of tons of F-gases leaks into the atmosphere only because of the self-made installations and disposal of mini splits and other small s. An other solution to solve this problem is banning pre-charging of F- gases in non-monobloc. Questions on potential impacts Who do you think will be most exposed to any negative impacts of a strengthened approach to F-gas emissions? (max 2 choices) Who do you think will benefit most from a strengthened approach to F-gas emissions? (max 2 choices) Companies servicing relevant products or Commercial or industrial users of relevant products or Individuals using relevant products or normally What type of application (if any) do you think will be most positively affected by a phase-down of HFCs? (max 3 choices) domestic refrigeration and freezers air-conditioning in motor vehicles others or no specific use category

4 What type of application (if any) do you think will be most negatively affected by a phase-down of HFCs? (max 3 choices) Which policy option do you expect to impose the greatest administrative burden? commercial refrigeration and freezing air-conditioning excluding room a/c, and a/c in modes of transport heat pumps establishing maximum, gradually declining limits to the quantity of HFCs placed on the EU market (phase-down) expressed in terms of CO2 equivalent How do you think a shift towards Harmful for competitiveness (specify alternatives having a lower or no below) global warming potential will affect the competitiveness and market shares of European businesses (or the business you represent)? Please, specify your expectations regarding the order of magnitude, e.g. expected percentage increase in costs To day only in limited applications alternative technologies are at least as energy efficient (or more) as HFC solutions. Also the supply of components is smaller and prices are higher. In most cases the applications are more complex (because of the properties of natural refrigerants). These reasons increases the costs for the contractor and then of course the price for the end user. In Denmark the change towards alternative refrigerants has also changed the structure of the contracting and service business. 10 kg charge limit for F-gases has splitted small and medium size companies mainly working in plants below this limit. Small amount of bigger companies takes care of bigger CO2- and NH3-installations (Kenneth Madsen: Living without HFCs - The Danish Experience, Institute of Refrigeration 11th March 2009). Most low GWP technologies entail higher costs for installers (training, insurance costs due to safety issues etc.) which makes a threshold especially for smaller companies. Additional comments Please include any additional comments you might have (max characters) or upload a document (max 1 document, if possible in MS Word, pdf or rich text format). In exceptional cases and only if you experience problems with this questionanire, you can also send us documents by (CLIMA-Fgas@ec.europa.eu). The assessment must always be done in light of the energy efficiency and total equivalent warming impact (TEWI) - not only in light of the GWP values. There is no one-size-fits-all solution to replace HFC refrigerants. The solution will depend on many factors such as the type and size of the solution, the cost of different alternatives, the availability of components and the feasibility of implementation. Whereas alternatives are mature for some systems, on others, energy efficiency may be much worse than the current norm equivalents. Low GWP solutions also present safety issues (flammability, toxicity, pressure). Endangering human lives in the name of climate protection is not justified. These safety issues have to be solved in all new solutions. Much more research should be carried out by independent research organisations before the final decisions concerning possible phase-out schedules of

5 HFCs will be made. Voluntary agreements for specific sectors where replacement is technically feasible and cost-effective is a good solution. The fast increasing market share of trans-critical carbon dioxide systems in Supermarket refrigeration is a clear indication, that even without any regulation or agreements a change to alternative solutions will happen. We only need to find more technically feasible and costeffective solutions.